It’s 9 a.m. Do You Know Where Your Contractors Are?

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As your company grows in sales and expands to accommodate more SKUs, greater inventory, new machinery, and additional employees at one time or another, your business is going to need help from an outside contractor.  They may be in the form of an engineering consultant, general contractor, painter or other types of specialists needed for a project well beyond your or your staffs’ current expertise.

When you make that final selection on your outside contractor before you sign anything make sure to do your homework and check up on their history.  If it all comes back good and you’re ready to offer a contract for the work to be done, on their first day at your facility they should be treated like any other new or temporary/seasonal worker that you bring in and participate in a safety orientation before doing anything. 

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Why?  They don’t know what your expectations are on safety and you don’t want to assume they do.  They don’t know your facility very well and you want to make sure as heck that they don’t contaminate your staff with their bad habits.  You also want to make sure they know that if their workers don’t follow those rules at your facility they’ll be banned from entering.  It’s your facility, your rules and you don’t need additional headaches because an outside contractor couldn’t follow direction and is now in need of medical attention.

You’d be amazed how many outside contractors are injured or killed every year on the job because they either cut corners on safety procedures, were traveling (via foot, electric cart, forklift) in an unfamiliar layout, lack of training or the company didn’t communicate instructions to them properly or incorrectly.  Here’s a contractor who’s paying a hefty fine for not following safety rules.  OSHA Fines Contractor $94K After Worker Burned At McDavid Sawmill and here’s another contractor being investigated for a chemical spill, OSHA investigating contractor B.L. Harbert over Birmingham Water Works chemical spill

As I stated earlier, it’s amazing the number of contractors injured or killed and it appears this is becoming a more serious problem as the numbers have increased.  A sharp rise in US contract workers killed on the job

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We hired an outside contractor to do some work on a new production line we were installing and it involved electrical and concrete work.  The main mode of transport within the facility was by man-lift, elevator or stairs with man-lift being the main one and the rule was if you rode the man-lift you didn’t carry a backpack, tools or other cumbersome items.  If you dropped it someone could be injured below or if it got caught riding up you could fall.  Our maintenance crew knew to take their carts and equipment up by the elevator.  The outside contractor didn’t go through any safety orientation as the company assumed all would be well.

A few days after the work began there was a commotion on one of the upper levels in the facility and our in-house emergency team responded to a call at the north man-lift where someone had fallen.  It was one of the contractors and it was bad enough that a call was made to 911 for an ambulance.  He was in a rush and had decided he didn’t want to wait for the elevator but took his tools up the lift with him and wound up falling two stories.  He broke both ankles, a leg, two ribs, a shoulder and sustained back and head injuries.

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The very next day the company had every manager doing recertification on every employee in their department.  I had to watch all 60 of my staff get on the lift, one at a time go up one flight, get off and then come back down one flight.  Documented it for all and then had myself recertified.  A fun evening was had by all.  Here lies the problem.  When you don’t take care of business the right way the first time, by proper training, proper documentation, you wind up spending and wasting time documenting while trying to keep production going full speed just to cover the company’s ass.

However, this will not be a problem at your facility and you will be in full control if you follow these guidelines:

  1. This is your facility, your rules, you are in charge!  As the supreme leader responsible for what goes on, it’s your rules of the road that are followed to protect everyone from employees to outside visitors.
  2. Any individual from the outside contractor must complete your in-house safety orientation. This is important especially if your facility has man lifts, elevators, confined spaces, danger areas, and flammables.
  3. Constant sustained communication between the contractor and you, the hiring company is critical to everyone’s safety.  What equipment will they be using that day, noise level, dust level and so on?
  4. To achieve #3 designate a point person at your company for the contractor to communicate with, answering any questions at any time while the contractors are physically on-site.
  5. Check-in and check out daily with the contractor.  Greet them upon arrival, go over any new details and see them when they leave.
  6. Stop by periodically to touch base and see how the work is progressing and that the contractor’s workers are not wondering anywhere they shouldn’t be.
  7. Don’t hesitate to ban any outside worker not following the rules or committing an unsafe act.
  8. It’s your facility, you are in charge, be in charge.

 

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The TopTen OSHA Violations Before Christmas. On the Eve Day

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It’s Christmas Eve at the Northpole and everybody is busy and celebrating!  Santa and the elves did an outstanding job of fixing all the violations which included hours of training and practice and then completing the seemingly impossible task of getting all the toys and gifts that boys and girls around the world had asked Santa for produced and loaded on the sleigh!  This could only have been accomplished thanks to the great team effort of the elves.

That’s what it takes when it comes to safety at the workplace,  It takes a team of dedicated workers watching each other’s backs and reminding how to properly deal with hazards.  Even if the call for safety doesn’t come from the top executives you can still control what goes on in your work area.  You make the decision to wear your PPE, (safety goggles, ear protection, dust mask, and bump caps.  You make the decision to wear your fall protection gear, you make the decision to work on your machine without LOTO.  You make the decision to inspect your forklift before using it.

It is against the law to bully or threaten an employee to commit an unsafe act.  It is against the law to tamper with any kind of safety shutoff.   Yes, some companies are disrespectful dumbasses and may fire you for insubordination but do you want to work for a company that doesn’t care enough about whether you live or die on the job?   You do have OSHA in your corner.  That’s why they have an 1-800-321-6742 (OSHA) HOTLINE.  

Tomorrow is Christmas day, and around our beautiful country, as families gather and celebrate the holiday, there will be over 5,000 empty seats.   Mothers, fathers, sons, daughters, uncles, aunts, cousins will not be there because they died in an industrial accident this year.  We will miss the way they carved the ham, that special pie she made, the awful jokes Uncle told or the great laugh she had.  They will be missed and the heartache will have to be relived all over again.  We are all like snowflakes, no two alike.  Each with our own combination of skills and talents which makes us unique.  We come into this world for a short time to accomplish goals, have families, make a comfortable living.  You never know if they were the one with the next cure for a disease or invention to benefit the human race.

Thank you for stopping by and taking time out of your busy day to read our presentation of the TopTen OSHA Violations before Christmas.  The reception has greatly exceeded our expectations and that’s only because of great fans like you. Thank you.  Wish you all a Happy Chanukah and a Merry Christmas.

 

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The TopTen OSHA Violations Before Christmas. On the Tenth Day

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Santa received a notice of violation(1926.501) Fall Protection-General Requirements and this unfortunately still #1 on OSHA’s TopTen violations for 2019.

In fact, falls have been the number 1 cited violation since 2011 and shows no sign of loosening its grip on that distinction.  This is very frustrating since falls can be stopped with the use of one word, NO.  If your foreperson or boss tells you we don’t have the time for you to put on your safety gear and properly tie off tethers to finish work on the roof just tell them I don’t have the time to die today, so NO!

Why?  Let’s say you do the right thing and wear your harness and all the gear needed.  You grab that 4×8 sheet of plywood to take it across the roof when a gust of wind catches the board like a sail and pulls you over the edge.  However, your fall is suddenly stopped by the tether and as you wait to be pulled up, you realized you lived and have a good tale to tell.  Meanwhile, in an alternate universe, you decided the boss is right and not to wear any of your protective gear.  Your reasoning, it’ll only take a second to move that sheet of plywood to the other side of the roof and it’s almost quitting time.  As you carry the board across the roof a gust of wind grabs the board and pulls you over the edge and as you plummet there is no sudden jerk from the tether to stop your fall but you have enough seconds to think,, rethink and rethink your mistake, your family, your kids until the ground breaks your fall.  If you are lucky the fall killed you instantly, no pain or suffering if you are not, expect a long life of pain, rehab, therapy, and disability.

So as you see the choice is yours.  It always has been.  Never allow anyone to challenge your courage, your manhood, your personality, your culture,  your capability to be a team player or other abilities just to goad you into committing an unsafe act or be bullied or threaten your job to do the same.  The law protects you.  Call the OSHA HotLine at 1-800-321-6742 (OSHA). 

Santa’s crew is training on how to properly wear their harness and how and where to properly tie off tethers before working right after they spent time learning what hazards to look for before working at any height over 6 feet, (9 feet in Arizona) since there are so many other ways to die from a fall.  Mis-use of ladders, poorly assembled scaffolding, side rails with missing sections, unmarked holes in the floor, wet or slick floors, distraction while working with spinning or vibrating equipment.  This is why you always inspect the area and safety equipment to be used before beginning work and never use any safety equipment that is damaged, frayed or altered.  What good is a side rail going to do for you if a section is missing to stop your fall?  What good is a rope rated to hold 100 lbs., when you weigh 220 lbs.?  Get in the habit of asking questions. The answers you get will give you enough insight to tell you if you want to continue working for that company.  If they give you answers and take safety seriously you found a keeper,

Santa’s Northpole workshop as well as your fall prevention program should include:

  1. Training – Identification of fall Hazards, how to wear and use PPE, anchoring tethers/lanyards and other associated items.
  2. Live demonstration and practice wearing and using.
  3.  Document all training including signatures of attendees, the material covered and who conducted the training.
  4. Enforce the rules, evenly and consistently.
  5. Group inspection of PPE  Equipment needs to be inspected on a regular basis, what better way to turn it into a safety training.
  6. Morning Huddle is a good tool to keep everyone in the loop as to what’s going on and any changes that are being made.
  7. Training – This is not one and done.  Don’t hesitate to have a refresher especially if you feel your staff needs it.

That was the last violation.  I believe Santa has complied fully and should get a clean bill of health but then you never know what the grinch has up his sleeve.  TOMORROWTHE DECISION

 

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The TopTen OSHA Violations Before Christmas. On the Ninth Day

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Santa received a notice of violation(1910.1200) Hazard Communication #2 on OSHA’s TopTen violations for 2019

Santa admits that he’s been so busy running the family business that he has not always kept up with changes.  He was very surprised to find out that his old MSDS book was incredibly out of date.  Back in 2012, the U.S. joined the Globally Harmonized System (GHS) which makes it easier for companies in classifying, labeling and producing data sheets for chemicals by complying with one system, globally.  As of June 1, 2016, it became mandatory for all U.S. companies under Hazard Communication Standard (HCS) or as it’s also referred to HazCom.

If you work where chemicals are produced, stored, shipped, transported or used you face a number of health hazards including irritation of skin, eyes or lungs and physical hazards like flammability or corrosion.  That is why you must have training on HCS and understand the processes and procedures that you must use in the handling, shipping or any form of exposure to chemicals.  All of the information is included in the Safety Data Sheets (SDS)  and labeling of item requirements.  The Safety Data Sheets should be located at every warehouse or facility where it is accessible by ALL.  Anyone who is involved, the truck driver loading chemicals, the UPS driver delivering, the dock forklift driver, the order picker, the clerk at the cheap retail store.  You all should have access to the SDS so you know what you are dealing with, what protective measures you must use and what to do in the case of a spill or leak.  The main change between old MSDS and current SDS is the order the information must appear:

  1. Identification
  2. Hazard(s) identification
  3. Composition/information on ingredients
  4. First-aid measures
  5. Fire-fighting measures
  6. Accidental release measures
  7. Handling and storage
  8. Exposure controls/personal protection
  9. Physical and chemical properties
  10. Stability and reactivity
  11. Toxicological information
  12. Ecological information
  13. Disposal considerations
  14. Transport information
  15. Regulatory information
  16. Other information

Santa and crew are busy updating their SDS and chemical handling procedures as well as training,  It feels like we cleared a pretty big hurdle but the biggest is yet to come.    Monday: On the Tenth Day. 

 

 

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The TopTen OSHA Violations Before Christmas. On the Eighth Day

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Santa received a notice of violation(1926.451) Scaffolding which is severe making it #3 on OSHA’s TopTen violations for 2019.

Think of scaffolding as another way to keep you from falling.  It gives you a stable platform to work on at several stories high if needed.  You can surround your project with scaffolding and work on it safe from all angles while stacking materials and using small pieces of equipment.

There are several kinds of scaffolding.  Single or brick layer’s scaffolding, Double, Cantilever, Suspended, and Trestle.  No matter which one you use it is only as good as it’s base so only a certified individual should direct and train other workers on its assembly.

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Santa forgot to have one of his fore-elves certified and would have understood the procedures to control or minimize the hazards associated with erecting scaffolding and to train other elves so they may participate and assist in the construction.  So guess what?  Here again, training is critical for the safety of everyone involved.

  1. Plan ahead
  2. What kind of conditions will you be dealing with and for how long?
  3. How many people and what kinds of equipment and materials will be used?
  4. Pick your scaffolding
  5. Inspect
  6. Refresher training with all workers involved and how you’ll all proceed
  7. Assemble scaffolding
  8. Inspect. Never assume.
  9. Inspect
  10. Inspect
  11. Taking it down can be as dangerous as putting it up if not more.  Pay attention and stay focused.
  12. As with all training, document with signatures and a copy of the materials used.

It seems like it’s been a long week with so many issues cleaned up at Santa’s workshop and we are now down to the top two.   Friday: On the Ninth Day. 

 

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The TopTen OSHA Violations Before Christmas. On the Seventh Day

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Santa received a notice of violation(1910.147) Lockout/Tagout and this is serious enough to be #4 on OSHA’s TopTen violations for 2019.

Lockout/Tagout or LOTO as it’s also known as is a pretty important safety feature that prevents unexpected operation of a piece of equipment while you are working on it.  You see the scene played over and over on comedies, One guy is working on an electrical issue and his friend comes over and flips on the light switch leading to shock and laughter but imagine the horror on your face if a packaging machine with moving belts and rotating filler spouts suddenly started up while you were up to your elbows in the machines main compartment!

Or worse, clearing a jam on a belt in a machine and because you thought you would save time by just reaching in clearing it quickly, but as you clear it the belt suddenly lurches and takes two fingers with it.  This actually happened at a food manufacturing plant and I can assure you that no elves were injured during the writing of this post.

This is why as I’ve said before and will again and yet again training is critical to a great safety program.  It’s not enough to just turn off the power with the flip of a switch before servicing the machine, you want to make absolutely positively sure that no one but YOU can turn the power back on before your work is done.

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That’s why this year Santa will be giving his machine operators, maintenance elves, and fore-elves the gift of their own LOTO sets.  Santa wants to do the training of LOTO  correctly so he will have his machine operators do an actual LOTO demonstration for the group for each piece of equipment.

Whenever you need to do maintenance, adjustments, line changes or clear a jam you must Lockout/Tagout the equipment so it can not operate while you work on it.

  1. Determine where to cut the power and use your lock. Your tag should have your name and department on it along with what ever other information the company wants.  Some want employee number, so anyone coming by knows you are the person working on that machine and initiated the lockout.
  2. In most cases, you pull the lever of the circuit breaker down so you can lock it in the off position.  In some older facilities, you may not find circuit breakers to lockout.  Find and pull the fuses and use the special fuse lockout.  Before beginning make sure the machine is totally deenergized as some parts mid-stroke may still move.
  3. Each additional worker who needs to service the machine along with you also needs to lock out the same source of power as you. As they finish their segment they can then remove their lock until the last person responsible for the project removes their lock and returns power.
  4. Never remove your lock until the work is completed.
  5. Never give your key to your lock to anyone else.  Only YOU can unlock it.  If you have to leave have your relief lock out the power source with their lock and then you can remove yours.
  6. Never allow anyone to bully you into removing your lock before work is completed.
  7. As with all training, document it with signatures of attendees and the material covered.

Now that we know all about LOTO. Thursday: On the Eighth Day.

 

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The TopTen OSHA Violations Before Christmas. On the Sixth Day

 

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Santa received a notice of violation(1910.134) Respiratory Protection and this is #5 on OSHA’s TopTen violations for 2019.

Your lungs bring fresh oxygen to your brain, organs, and tissues via the circulatory system and then expel carbon dioxide with every breath you take.  When O2 levels are where they should be, your body functions at its peak.  However, your lungs can also transport toxins to those very same organs while also damaging themselves over a period of time causing debilitating diseases and a slow death when oxygen can no longer reach and organs fail but in some instances, contact with the toxic fumes can bring instant death.  It turns out Santa’s fore-elf, due to his own ignorance was not insisting that the elves wear their respirators properly in the paint shop.  Because of their beards, the respirators were not fitting correctly and leaving a gap in protection and allowing fumes to accumulate in the mask rendering it useless.

Working with solvents, chemicals, paints, lubricants, dust-producing equipment and any other toxic air causing materials is a dangerous job.  Some hazards are easy to see like sawdust at a mill and some are colorless and hard to detect but all are toxic to your lungs and when working with them in a confined area like a paint shed or storeroom it makes their effects even stronger and without proper protection can overwhelm you in seconds rendering you unconscious and death.  There have been incidents, luckily not at Santa’s workshop where someone passed out after entering an area with toxic fumes and the next person rushes in to rescue them, without a respirator, only to succumb to those same fumes themselves because they are so overpowering and both workers wound up dying.

When working under these conditions like a wood mill or paint room at Santa’s workshop

  1. Choose the correct mask for the job.
  2. Even if it has a venting system you still must wear the properly rated respirator to protect yourself.
  3. No matter what type of mask you need to wear, they need to fit tightly on your face so there are no gaps to allow dust or toxins in.  The vendor will work with your employees to teach and accomplish that.
  4. That means you may have to shave facial hair to ensure that tight fit.
  5. Training on how to wear their respirators and as always, document the training.
  6. Take proper care of respirator and clean and change filters per manufacturer’s instructions.
  7. If respirators are part of an emergency response kit make sure to test and check them to ensure their availability when needed.

Santa continues to work with OSHA while upgrading the workshop into the twenty-first century.  It won’t happen overnight but then Santa is magic.  Wednesday: On the Seventh Day.

 

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